The tariff classification of a disassembled Card Expressmachine from Canada

NY 866780 October 7, 1991 CLA-2-84:S:N:N1:103 866780 CATEGORY: Classification TARIFF NO.: 8476.19.0000 Mr. Michael M. Young Pronto Printer 550 Cooper Center West 7150 N. Park Drive Pennsauken, NJ 08109-4212 RE: The tariff classification of a disassembled Card Express machine from Canada Dear Mr. Young: In your letter dated August 26, 1991 you requested a tariff classification ruling. The Card Express is a vending machine which prints small quantities of business cards, invitations, announcements, or similar articles. It is a free-standing machine essentially comprised of a vandal-proof cabinet incorporating a touch screen, computer, film feeder and printer assembly, paper feeder, paper cutter, and a unit which accepts money. Upon depositing the required amount of money an instruction program will be displayed on the screen. The program offers a choice of 4 card sizes, 26 layouts, and 5 typefaces. The customer selects the desired card size, layout, and typeface, as well as the desired wording, by touching the appropriate spot on the screen. After the selections have been made, a thermal transfer printer prints 50 business cards or 25 double-sized invitations in about a minute. The Card Express machine is intended for installation at conference and exhibition centers, airports, print shops, and similar locations. It measures 54 inches high, 24 inches wide, and 24 inches deep, and has the capacity to supply up to 154 customers before resupply is required. You state in your inquiry that, except for the film feeding and printing assembly, the entire Card Express machine is composed of components of Canadian or U.S. origin. The film feeding and printing assembly is made in Japan, shipped to a U.S. distributor, and then transshipped to Canada for assembly into a Card Express machine. After testing, the complete machine is disassembled and shipped back to the U.S. where your firm re- assembles it and ships it to its final location. You state all of the disassembled components, including the film feeder and printer assembly, will be shipped in one crate. The General Rules of Interpretation set forth the manner in which merchandise is to be classified under the Harmonized Tariff Schedule of the United States (HTS). General Rule of Interpretation 2(a) states, among other things, that any reference in a heading to an article shall be taken to include a reference to that article complete or finished, entered unassembled or disassembled. Accordingly, the applicable subheading for the complete but disassembled Card Express machine, imported in a single crate, will be 8476.19.0000, HTS, which provides for other automatic goods vending machines. The duty rate will be 3.9 percent ad valorem. Goods classifiable under subheading 8476.19.0000, HTS, may be entitled to a free rate of duty under the United States- Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations even though they contain components which are not of Canadian or U.S. origin. A copy of the applicable regulations is attached for your information. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport